TPO cannot take cognisance suo moto of any international transaction for adjustment in ALP

CIT Vs. Amadeus India Pvt Ltd (Delhi HC) – Role of Transfer Pricing Officer (TPO) is limited to determination of the Arm’s Length Price (ALP) in relation to the international transaction(s) referred to him by the Assessing Officer (AO). The TPO, on a suo moto basis, cannot take cognisance of any other international transaction not specifically referred to him by the AO. It is primarily the duty of the AO to compute any income arising from an international transaction having regard to the ALP. The AO may determine the ALP of an international transaction himself or, as stated in Section...